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Guidance: 2013-14 Title I, Reservations, Allowed

Consolidated Application, Winter Release program guidance for the 2013-14 Title I, Part A, Reservations, Allowed.

Reservations are not calculated on carryover funds. As such, percentages are calculated based on the "Title I Part A entitlement after transfer" rather than on the "Total allocation".

Proportional Amounts of Reservations for Nonprofit Private School Equitable Services

LEAs must annually calculate the correct amount of funds to provide equitable services for participating private school students, their teachers and families. If an LEA reserves funds off the top of its Title I allocation for district-wide activities, the Title I regulations require that the LEA must also provide equitable services from these set-aside funds (34 CFR, Section 200.65). Some of the examples for the district-wide set aside are: instructional activities (such as assistance to schools, funds set aside for reading coaches, summer school, etc.), professional development, and parent involvement. The amount of funds available to provide equitable services from the applicable reserved funds must be proportional to the number of private school children from low-income families residing in participating public school attendance areas.

Professional Development: The consultation with private school officials is critical to providing appropriate professional development activities for teachers of Title I participants in the private schools. If an LEA reserves funds under ESEA Section 1119 off the top of its Title I allocation for carrying out professional development activities, the LEA must provide equitable services to teachers of private school participants from this set-aside. As required under 34 CFR, Section 200.65, an LEA must calculate these equitable services from the funds that are reserved.  Equitable services must be calculated in proportion to the number of private school children from low-income families residing in the participating public school attendance areas. It is not sufficient to merely extend an invitation to eligible private school teachers to attend the same professional development activities planned for the LEA’s Title I teachers. The professional development activities for the teachers of Title I participants must be planned and implemented to address how those teachers can better serve Title I students, such as by providing information on research-based reading and mathematics instruction. Consultation with private school officials will determine whether the LEA provides for these activities independently or in conjunction with the LEA’s professional development activities.

If a private school chooses not to participate in the professional development activities (the private school officials feel that their teachers’ participation in Title II provides adequate levels of professional development to address the needs of Title I students), the district cannot combine professional development funds with the instructional funds for services at the private schools. The professional development funds must be spent on professional development or returned to the district’s Title I funds.

Frequently Asked Questions on Equitable Services

Q. Does the equitable services requirement in 34 CFR, Section 200.65 apply to LEA set-aside for LEA and school PI activities?
A. The equitable services requirement does not apply to Title I Part A funds reserved for LEA and school PI activities.

Q. How does an LEA meet the equitability requirement for professional development?
A. Professional development funds set aside by PI LEAs (required minimum of 10 percent) are not subject to the equitability requirement. If an LEA reserves funds under ESEA Section 1119 off the top of its Title I allocation for carrying out Title I professional development activities, the LEA must provide equitable services to teachers of private school participants from this set-aside. As required under ESEA Section 200.65, an LEA must calculate these equitable services from the funds that are reserved.  Equitable services must be calculated in the proportion to the number of private school children from low-income families residing in the participating public school attendance areas. Activities for the teachers of private school participants must be planned and implemented with meaningful consultation with private school officials and teachers.

Example—Allocating Funds for Equitable Services for Private School Teachers: An LEA reserves six percent ($360,000) of its Title I allocation of $6 million for professional development as required under ESEA Section 1119. The number of public and private school children from low-income families residing in participating Title I attendance areas is 25,000. Five percent of the 25,000 children attend private schools; thus, five percent of the $360,000 reservation ($18,000) is available for equitable services for the teachers of private school participants. The professional development activities funded by Title I must meet the needs of the teachers of private school participants. After consultation with the appropriate private school officials, the LEA may conduct these activities independently or in conjunction with the LEA’s professional development activities.

Q. Does the equitable services requirement in Section 1120(a) apply if the LEA takes funds off the top of its Title I allocation for summer school programs?
A. Yes. Since a Title I summer school program provides instructional services, ESEA Section 200.64(a)(2)(i)(A) would apply and requires the LEA to provide equitable services to eligible private school children. The LEA must base equitable services supported with the reserved funds on the proportion of private school children from low-income families residing in participating public school attendance areas.

Q. Does the equitable services requirement in ESEA Section 1120(a) of the Title I statute apply to LEA set-asides for preschool programs?
A. The equitable services requirement does not apply to children attending private preschool programs because the state of California does not consider preschool to be part of elementary education.

Salary Differentials

An LEA, rather than a school, may fund variations in personnel costs, such as seniority pay differentials or fringe benefits differentials. This policy would have to be applied consistently to staff serving both public and private school children throughout the LEA.

Any salary differential costs that pertain to administrative rather than direct service staff should be recorded on the Title I Part A LEA Allocation page in “Administrative reservation."

Preschool Programs

For further information and federal guidance see the CDE Title I Part A Preschool Programs Web page.

Technical Assistance to Schools

The LEA bears the primary responsibility for ensuring that the school in improvement receives technical assistance as it develops or revises its SPSA and throughout the plan’s implementation. United States Code Title 20 (20 USC) sections 6312 (b)(1)(A),(L); 6316 (b)(4)(A),(B),(C). Technical assistance is practical advice offered by an expert source that addresses specific areas for improvement.

The LEA is not required to provide the technical assistance directly, although it may choose to do so through mechanisms authorized under section 1117. Other acceptable technical assistance providers include the SEA; an institution of higher education; a private, not-for-profit or for-profit organization; an educational service agency; or another entity with experience in helping schools improve academic achievement. Regardless of the provider, technical assistance provided to a school must be based on scientifically based research.

Technical assistance for a school identified for improvement must focus on strengthening and improving the school’s instructional program. In providing technical assistance, the LEA has the opportunity to support thoughtful analysis and capacity building at the local level, both of which will not only help schools to improve, but will also help them to sustain their improvements over time. To do this, the LEA must help the school address the issues that caused it to make inadequate progress for two consecutive years. Specifically, the LEA must ensure that the school in need of improvement receives technical assistance based on scientifically based research in three areas: (20 USC Section 6316 (b)(4)(C).)

Assisting schools in need of improvement creates a major accountability challenge for LEAs. Because many schools have been, or will be, identified for improvement under the rigorous accountability provisions of ESEA, LEAs may be tempted to consider formulating a single assistance plan for all of its schools that are designated for improvement. To the extent feasible, LEAs should avoid taking this approach. Schools in need of improvement are more likely to need individualized assistance comprised of strategies and interventions that recognize and address their unique student needs. 

It is crucial that the LEA align its assistance with the SPSA developed by the school. Both the SPSA and the LEA assistance plan should be based on a close analysis of the school’s demographic and achievement data, such as on subgroup performance, and a comprehensive needs assessment that identifies both strengths and weaknesses. Involving teachers, school administrators, and parents in this planning and decision-making is crucial to the successful design and implementation of the LEA’s assistance.

To assist in providing technical assistance to schools in need of improvement an LEA may reserve funds from its Title I, Part A (20 USC section 200.77), however it is necessary to remember that Title I, Part A is built on the concept of operating programs in eligible schools for the benefit of their eligible at-risk students’ specific needs. For this reason programs funded by Title I, Part A and Economic Impact Aid/State Compensatory Education, must use no less than 85 percent of their apportionment at school sites for direct services to students. (EC sections 54420, 63001.) 

In addition to using no less than 85 percent of their apportionments at the school sites for direct services to students, an LEA is required to provide equitable services to eligible private school students from their Title I, Part A allocation. (ESEA section 1120.) If an LEA were to reserve large amounts “off the top” of its Title I, Part A allocation for such activities, it could effectively reduce the equitable services available for private school students. Accordingly, an LEA may not reserve all of its Title I, Part A funds “off the top” of its allocation to use for district priorities. In addition, because the reservation of funds by an LEA will reduce the funds available for distribution to participating areas and schools, the LEA must consult with teachers, pupil services personnel (where appropriate), principals, and parents of children in participating schools in determining what reservations are needed to provide technical assistance to schools.

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